Data is not effectively anonymised (but does not relate to NHS service users or NHS staff)
The data you plan on using for your study is not effectively anonymised from a legal standpoint. It is considered ‘personal data’ and is therefore subject to the UK General Data Privacy Regulation (UK GDPR).
The data does not relate to NHS (or other care) service users or NHS staff. It is not under the remit of the Health Research Authority (HRA) in England and Wales nor the authority of devolved administration equivalents.
What you need to do
Your usage of data raises data protection (including privacy) risks. You will need to assess if you are using your data in line with UK GDPR. See Data protection: The Data Protection Act - GOV.UK (www.gov.uk)
What we recommend
To avoid any breaches of the UK GDPR, we strongly advise reconsidering your data solution. Could you use a dataset that has been shown to be effectively anonymised? Could the data undergo a process of anonymisation before you use it in your study?…
Understanding the data requirements for your project is the first step in your research journey. This tool should have assisted you in thinking about the essential considerations on the use of data for health and social care research. Please do ensure that you think about the most appropriate data you need for your study and whether your data access needs would meet the statutory and legal governance requirements in the UK. It is imperative that data used for the development of AI and data-driven interventions is accessed with the highest privacy and ethical standards. Spending time to identify the data you need, understand what data is available and consult the relevant people and organisations, may ensure that your project can get started as soon as possible with minimal delays.
Resources on data anonymisation
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HRA Data Decision Tool Feedback Form